Quote:
Originally Posted by Icky Thump
I will give you the most famous of all legal answers: It depends.
Really depends what the p. order says. It seems yes you can use in dep of B whether by PMK or CEO. Technically a party.
You can always ask a hypo or nibble around the content without using the actual doc too.
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I'm with Icky - it's really amazing how often "it depends" is the correct answer.
Is Company B a party to the case with the protective order? Does the PO say anything about use of eyes only docs at depos?
In the past, I've either said something like "did you send an email to Sidd Finch about 2nd quarter 2014 widget pricing?" (after setting it up with general questions about whether B's CEO communicated with anyone), or went thru the PO process of removing the eyes only designation on multiple documents (so as not to tip my hand on the ones I really want to use).
Good luck.
